ML20076N106

Applicant Response to Board 910122 Memorandum & Order.* Intervention Dismissed & Proceeding Terminated Due to Listed Reasons.W/Certificate of Svc

ML20076N106
Person / Time
Site:	Vogtle
Issue date:	03/20/1991
From:	Blake E, Domby A GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20076N108	List: ML20076N106 ML20076N112 ML20076N123 ML20076N132 ML20076N146 ML20076N150
References
CON-#191-11564 90-617-03-OLA, 90-617-3-OLA, OLA, NUDOCS 9103280093
Download: ML20076N106 (11)

Text

14; .

~

,0?",/l$I b kh .

4 i Ut d ILD U5HhC UNITED.3TATES OF AKERICA '

NUCLEAR REGULATORY COMMISSION '91 IN N P 3 55 ATONIC SAFETY AND LICENSING BOARD ip s \Lc te ['l34

m;(;fh In the Matter of a 1 Georgia Power Company '

it 11.s 8 t

(Vogtle Electric DOCKET NO. 50-424-OLA Generating Plant, 3 50-425-OLA Units 1 and 2)

• ASLBP NO. 90-617-03-OLA APPLICANTS' RESPONSE TO THE BOARD'S MEMORANDUM M ORDER OF JANUARY-22. 1991 INTRODUCTION On January 21, 1991, this Licensing-Board conducted a telephone conference call for the primary purpose of posing certain clarifying questions derived from filings by the Appl.icants and associated responses submitted by GANE and the NRC Staff. The Board's January 22, 1991 Memorandum and Order set forth eight questions. The Board ordered the Applicants-to file tbeir responses to six of the questions by March 22,

-1991. The Staff was ordered to file its responses to two of the questions by the same date. GANE was ordered to file a calculation of diesel engine temperature rise to which it had-alluded as soon as possible, but in no event later than March 22, 1991; GANE filed its calculation by letter dated January 22, 1991.

9103280093 910320 PUR ADOCK 05000424 S O PDR Q r

a l O' l .

On February 4, 1991, the NRC Staff filed a motion for reconsideration of the Licensing Beard's January 22, 1991 Order and requested a stay of the effectiveness of that Order. Thereafter, the Board invited the Applicants and GANE to tile responses to the Staff motion by no later than February 25, 1991. Both the Applicants and GANE did so. By Memorandum and Order of February 28, 1991, the Board denied the NRC Staff's motion for reconsideration, but permitted the Staff to decline to answer the two questions posed to it.

RESPONSES TO OUESTIONS The Applicants are providing the Board with answers to the six questions posed to it in the Affidavits attached to this Responsa. The Board will note that the Affidavits not only provide a specific answer to the question, but also set forth additional information associated with the answer in order to avoid the need for further clarifying questions. The Applicants also address one of the questions posed to the NRC Staff. The Applicants believe that, based upon the Affidavits and other information submitted by the Applicants and the NRC Staff coupled with the lack of basis pled or provided by GANE, the Board readily may conclude that the 2

- - - - - - - - _ - _ . _ _ . _ _ _ _m _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _

t

.c . . . k iC

,M, 1 1

1

'Sp operator in the-control room has sufficient time to react appropriately.:to an abnormal-diesel generator condition.1 ouestion'11  !

ThefBoard'sLinquiry regarding the obligation to dispatch l anLoperator (either-licensed or qualified plant equipment Loperator)-- to the diesel tengine in the event- of an automatic

-1 dieselistart is addressed in the Affidavit of Mr. William F.

a' 2 -Kitchens,:the-. Assistant General Manager-of the_Vogtle

Electric _ Generating-_Pl' ant. Plant procedures do mandate this g dispatch. Mr.

John David Lisenby explains.in his Affidavit"

-.why.the use of the permissive. word "should" was appropriate in the: Design 1 change Package-("DCP");previously provided the Board:: -compliance'with the design basis requirements does.

not depend-upon the dispatch of azlocal plant; equipment:or

.m licensed-operator.to the_ diesel-generatorE(Lisenby Affidavit s" s at 6).- The affidavitsLof Mr.:Lisenby-and-the NRC's Mr. Ralph .

b

'Architzelt(pp.;7-8)', conclude ~that regulatory requirements are: met. -Mr.ELisenby goes on to point outithat, indeed, -

i

? additional assurance exists- that scenarios examined: by the.

I As.the~ Board $has1 observed,-the sufficiency _of:.cperator '

i "

response time is not oneiof the explicit-contentions-filed.by;

GANE (Memorandum and Order ; of February' 28,1991 ati4) , and' GANE Lhas acknowledged thatlitJhad"not pled-anything about adequate v -

- operator response-time (Tr.162)~. Nevertheless,1the Applicants' understandingfis.that its Response;williaid the Board'in--its review ofLthe-contentions pled by GANE.

3 l

_ _ a2 __ _ _ __ . _ . . . - _ . . . . _ . _ _ . . _ _ . . . _ - . . _ - . . . . . . _ _ . _ _ . . . - - - - , _ . . _ . . . _ . _ . . _ -

t V '

DCP will be handled appropriately in light of the actual

. practice of dispatching the local operator (Lisenby at 8-9).

Question 2.

Mr. Lisenby also discusses the information which he has been able to glean concerning the nuclear industry's experience with the three-way valve that bypasses the -

NSCW/ jacket water heat exchanger. His conclusion is that a failure of the valve to open is remote given the information provided by the diesel engine vendor, by contacted licensees and by NPRDS data. Additionally, an Electric Power _Research Institute study, utilizing Licensee Event Reports from January ~1968 through September 1982, for all makes and models of diesel engines at licensed facilities and covering 11,044 total diesel-months of operation, identified five instances l

of " service water valves and controls" failures, representing a mean failure rate of .45 x 10-3 failures per diesel-month.

(EPRI Report NP-5924, Project 2235-1, entitled " Surveillance Monitoring and Diagnostic Techniques to~ Improve Diesel

, Generator Reliability," July,fl988 at p. 2-13). The time frame covered by these LERs is prior to the industry's broad and extensive efforts to increase diesel generator reliability during the 1980s. The Applicants do not know the nature of the " service water valves and controls" failures,

-since.the definition of failures on the LERs frequently 4

I'

.,-w -. - _ -

I l

l required EPRI to interpret an assignment of a failure to a specific system or subsystem. However, th's data supports and confirms Mr. Lisenby's conclusions.

Question 3 and GANE's Calculation of Encine Temocrature BIEA.

As the Board requested, the calculations used to ascertain the 10*F per minute temperature rise estimated by the

-Applicants and provided to the NRC Staff in December, 1990, are provided in Mr. Lisenby's Affidavit (Attachment A). The calculation is for the diesel engine under a load of 5517 Kilowatts, the maximum LOSP load specified in the VEGP's FSAR (Table 8.3.1-2). He also explains that the 10'F per minute rise would apply for the temperature rise of the diesel generator prior to the 190'F jacket water temperature alarm.

Thus, at least three (3) minutes would be available for a dispatched operator to reach the diesels prior to a temperature of 190*F, assuming three-way valve failure in the closed position, since the standby temperature of the jacket water is approximately 145'F.

5

J~

fh.

o.

GANE's calculation of' engine temperature rise provided to the Board has a fundamental error as explained by Mr. Lisenby (Lisenby Affidavit at 11).2 With respect to the Board's question concerning start-up observations-of diesel generator temperature rise, the Applicants understand ths question to relate to temperature rise before the three-way valve opens, as articulated by Judge Carpenter during the January 22 conference call. The standby temperature of the jacket water (i.e., prior to diesel start-up) is approximately 145'F-and the three-way valve. opens at approximately 151'F. The valve' opening, therefore,foccurs shortly after start-up. During early April, 1990, the Applicants monitored the jacket. water temperature as part of its review of the March 20, 1990 event. The only relevant observation was a 7.5*F temperature i

drop within 40 seconds of the start. This observation merely confirms the cooling capabilities of the NSCW flow over a short period of time with the expected operation of the L

L three-way valve.

l 2

Accordingly, the Staff and the Applicants have provided the Board with expert opinions containing detailed calculations of engine temperature rise. In stark contrast, GANE has provided only questions, a calculation without attribution to an expert (which is patently erroneous) and'no factual basis pled in support of a contrary determination.

6 l

L

cr=

+

1

=

2 F 1 gngstion 4.

Mr.. Lewis Ward, who previously provided the Board with an Affidavit concerning the Calcon sensors, refers the Board to previously-oubmitted technical information and explains the method of sensor calibration in response to the Board's fourth question. An additional diagram of the sensors may be found in Appendix J, p. J-31 of NUREG-1410, which depicts the 0-ring in cross-section (black circles above and to the sides of the calibration ring which surrounds and is connected to the "setpoint adjustment disk").

Qggptions 5 and 6.

The Board's discuscion of Reg. Guide 1.9, position 7 during the telephone conference call may have assumed that the " testing" of trip features is conducted from the cont'rol room and that such " testing" includes testing of the sensors' actuation. As explained by Mr. Kenneth Stokes in his l

L Affidavit, testing is performed locally at the diesel engines l

l and,--further, the verification of the bypassed status of the L

circuits is the purpose of such testing. Procedural control and visual verification of the manually operated bypass ,

valves achit ,s this purpose and, therefore, complies with j the Reg. Guida. Also explained by Mr. Stokes is the.

1 Applicants' position that " abnormal. values of all bypassed parameters" as stated in the Reg. Guide refers to abnormal 7

L.

pressure, abnormal vibration and abnormal temperature (e.g.,

high temperature lube oil, high vibration, low pressure jacket water). Under the License Amendments, the bypassed HJWT trip currently is not alarmed in the control room, but the trip is a feature. not a parameter, and the presence of abnormal jacket water temperature is still alarmed at 190*F (Stokes Affidavit at 4).

Question 8.

Finally, the normal shift-manning requirements for operators at the facility assures sufficient qualified employees to be dispatched to the diesel engines upon emergency start (Affidavit of Charles Meyer). A representative example of actual shift-manning practices is also provided with Mr. Meyer's Affidavit.

CONCLUSION With the information provided by the Applicants and the NRC Staff, in the absence of sufficient pleadings by GANE to provide a factual and legal basis for contentions, and in light of GANE's failure to comply with the Commission's contention pleading requirements, GANE's petition for 8

intervention should be dismissed and this proceeding terminated.

Respectfully submitted, Arthur H. Domby u TROUTMAN, SANDERS, LOCKERMAN

& ASHMORE 127 Peachtree Street, N.E.

Atlanta, Georgia 30303-1810 (404) 658-8243 Y $ W . L er W Ernest L. Pl.ake, Jr ,"P.C.

SHAW, PITTMW, POTTS & TROWBRIDGE 2300 N Stroet, N.W.

Washington, D.C. 20036 (202) 663-8084 Dated: March 2o , 1991 9

p. ,

i' 0(.Ki i 1. D usHRC UNITED STATES OF AMERICA 91 nm 22 P3 56 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICEN8'iNG BOARD , , ,

,, y ,

Lg; ,: , -W i

. :. k ; <

In the Matter of GEORGIA POWER COMPANY, t

, 1.4 31 I Docket Nos. 50-424-OLA I 50-425-OLA

• ASLBP No. 90-617-03-OLA (Vogtle Electric t Generating Plant, t Units 1 and 2)  :

GZETIFICATE OF SERVICE This is to certify that copies of the within and foregoing

" Applicant.s' Response to the Board's Memoranduin and Order of January 22, 1991" were served, pre-paid to ensure proper delivery, via the United States Mail, First Class, or via Federal Express, overnight delivery, or via hand delivery, to all those listed on the attached service list.

This 22 day of March, 1991.

h A--$ .- Q ~f G- - %x, Arthur H. Domby .f TROUTMAN, SANDERS, LOCKERMAN

& ASFD40RE 1400 Candler Building 127 Peachtree Street, N.E.

Atlanta, Georgia 30303-1810 (404) 658-8243

_ ___ ___m___.____-.--___m__.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENdING BOARD ,

In the Matter of GEORGIA POWER COMPANY, 3 At 31.- 3 Docket Nos. 50-424-OLA 2 S0-425-OLA x

ASLBP Wo. 90-617-03-OLA (Vogtle Electric Generating Plant, t L Units 1 and 2)' I sfRVICE SIST Administrative Judge. Secretary of the Commission Charles Bechhoefer, Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 L U.S. Nuclear Regulatory ATTN Docketing and Seryices Commission. .

Branch Washington, D.C. 20555 L

Charles Barth, Esquire- -

Administrative Judge Office of General Counsel James H. Carpenter White Flint North

, Atomic Safety and Licensing Stop 15B18 L

Board Panel U.S. Nuclear' Regulatory U.S. Nuclear Regulatory' Caumission l

Commission Washington, D.C.- 20555 l

Washington, D.C. 20555 l- Director, l Administrative Judge Environmental Protection l Emmeth A. Luebke . _ Division 5500 Friendship Boulevard Department of Natural Apt. 1923N Renources L Chevy Chase, MD 20815 205 Butler Street,_G.E.

L Suite 1252 Ms. Glenn Carroll Atlanta, Georgia 30334 l

Georgians Against Nuclear

~ Energy-

.139 Kings Highway l Decatur, Georgia 30030 L

l I